Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
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